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May 8, 2020

Washington Dispatch for April 2020

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young LLP's International Tax and Transaction Services group, this monthly newsletter summarizes recent developments in US international taxation. Highlights of this month's edition include:


  • President Trump signs interim coronavirus relief measure; attention turns to COVID-19 bill #4 

IRS news

  • IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing; more certainty but some surprises
  • New anti-abuse rule targeting certain 'GILTI gap period' transactions included in proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules
  • Taxpayers need to consider international tax implications of making certain NOL elections under Revenue Procedure 2020-24
  • IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusions
  • IRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES Act
  • IRS provides relief for potential tax consequences caused by COVID-19 travel restrictions
  • IRS withdraws 2004 Notice on ‘Midco’ transactions

Transfer pricing news

  • IRS releases FAQs on transfer pricing documentation best practices
  • IRS issues annual APA report for 2019

OECD news

  • OECD BEPS 2.0 project to continue on current timelines
  • OECD Secretariat issues guidance on impact of the COVID-19 crisis on treaty-related issues
  • OECD releases second batch of Stage 2 peer review reports on dispute resolution 


Washington Dispatch for April 2020


The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


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